ML101810238
| ML101810238 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/2010 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Bayssie Mekonen/RES 251-7489 | |
| Shared Package | |
| ML101800482 | List: |
| References | |
| DG-5029, RG-5.010, RG-5.015 RG-5.080 | |
| Download: ML101810238 (7) | |
Text
Staff Responses to Public Comments on Draft Regulatory Guide DG-5029 (Proposed Revision of Regulatory Guides 5.10 and 5.15)
(Public comments have been edited for clarity)
Strategic Teaming and Resource Sharing (STARS) E.J. Brooks Company (Brooks)
Integrated Regulatory Affairs Group Security Products Group P.O. Box 411 8 Microlab Road Burlington, Kansas 66839 Livingston, New Jersey 07039 (ML093521575) (ML093521552)
Comments NRC Comment Resolution Originator DG-5029 Section Specific Comment NRC Staff Response STARS-1 2.2.2.2 In the third paragraph The staff has reviewed in section 2.2.2.2, a and considered the testing program comment. Regulatory should be utilized is guides only provide described. If the staff suggested methods of believes the complying with the manufacturers testing requirements set forth program is not in the regulations sufficient, then the found in Title 10 Code wording must be of Federal Regulations specific as to the types (10 CFR). Therefore, of testing necessary. this regulatory guide The current wording cannot require any will create confusion type of testing or as to what, if anything specify what testing is required. For should be conducted.
example, phrases This section is such as multiple included to suggest attempts and that licensees significant number of evaluate the attempts are manufacturer's testing subjective and open to program and conduct interpretation. The additional tests if Staff should state the necessary for site-requirements for specific applications.
testing and that the licensee has reviewed the manufacturers testing program for the seals and found it to be adequate or has otherwise sponsored a testing program.
STARS-2 2.2.3 The second paragraph The staff reviewed the in section 2.2.3 comment and revised provides suggestions the statement to that are not within the clearly indicate that scope of the RG. The the data in question is RG should not provide data related to the suggestions to the seal and container on
licensee on control of which the seal is data outside the scope applied. Records of of this RG. The seals and to which paragraph should be container they are deleted. attached are an integral part of the use of TIDs and PS seals and therefore fall within the scope of this regulatory guide.
STARS-3 2.2.4 Section 2.2.4 is The staff reviewed the outside the scope of comment and revised this RG. The control of the section to clearly the recorded data is indicate that the data not the subject of this in question is data RG. The section related to the seal and should be deleted. container on which the seal is applied.
Records of seals and to which container they are attached are an integral part of the use of TIDs and PS seals and therefore fall within the scope of this regulatory guide.
STARS-4 2.4.6 The second paragraph The staff has reviewed under 2.4.6 seems to and considered the contain an optional comment. Regulatory requirement. If the guides only provide desire is to get vendor suggested methods of verification that seal complying with the designs are protected requirements set forth and controlled, then in the regulations the paragraph should found in 10 CFR.
state that explicitly. If Therefore, all this is only a statements in this suggestion, the regulatory guide are paragraph should be suggestions and no deleted to prevent requirements are to be confusion between the set forth in any licensee and the staff. regulatory guide.
STARS-5 2.4.6.1 The last two The staff has revised sentences under the statement for 2.4.6.1 are clarification.
ambiguous. If the decals are not acceptable for the application, then it should be stated as such. If they are acceptable, delete the 12/10/2010 Page 2
last two sentences.
STARS-6 2.4.6.2 The last sentence of The staff has section 2.4.6.2 should reworded this section be deleted. The to clarify that the requirement of a incorporation of a company logo on a company logo is seal is beyond the optional and may scope of this RG. contribute to the authenticity of the seal.
STARS-7 3.2 All but the last An effective TID sentence of the third program requires that paragraph under only authorized section 3.2 should be personnel have deleted. It is not access to TIDs and appropriate for the RG data associated with to specify the TIDs. This paragraph organization of the describes a common licensee. The acceptable practice.
procedures and Other means of process in place are organization and adequate. procedures may be acceptable as well.
Brooks-1 Multiple sections Numerous comments The staff has reviewed throughout this and considered this regulatory guide comment. The NRC suggested the guide accepts barcodes for refer directly to the use in identifying seals use of new and the guide has technologies such as been revised to reflect RFID, GPS, Zigbee, this more frequently.
barcodes, and other At the present time the electronic NRC does not have technologies. sufficient information concerning the reliability of other new technologies such as RFID, GPS, and others to endorse their use for protection of special nuclear material. The NRC is actively studying the technology and if any use of new technology is found to be acceptable it will be noted in future revisions of this and other regulatory guides.
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Brooks-2 2.2.1 Rewrite the sentence Staff revised the on holographic logos statement in to include holograms accordance with this and logos that are suggestion.
printed in UV ink.
Brooks-3 2.2.1 Specify seals should This statement has have a unique serial been reworded to say identification number. code instead of number to include alpha-numeric combinations which are acceptable.
Brooks-4 2.2.1 Comment noted: Staff concur with this There can be no statement and this substitute for an area is addressed in effective, TID storage, Sections 3.1 and 3.2.
inventory and accountability program in place wherever TIDs are used. The assignment of specific individuals, with clear responsibilities for the same should be an integral part of any TID program.
Brooks-5 2.2.2 Comment suggested Section 2.4.5 covers referring to the fact specific braided wire that certain braided seals and includes this wire, cable TIDs information.
provide pre-formed cable. When the cable is cut, wire strands individually separate, making their reinsertion within the seal body nearly impossible.
Brooks-6 2.2.2 Comment suggested Staff concur with this that clear installation comment and the instructions that section has been emphasize critical changed to reflect this.
steps in installation should always be available.
Brooks-7 2.2.2 State that PS seal Staff concur and manufacturer added this language recommendations for both PS and TID should be followed on seals.
what seal should be used based on the 12/10/2010 Page 4
application surface conditions.
Brooks-8 2.2.2.1 Comment suggested A sentence has been that PS seals should added to state that be applied for 20 manufacturer minutes before recommendations for containers are how long seals should released. be applied before release should be followed.
Brooks-9 2.3 In the discussion of This comment is removing remnants of included here and in voided seals from Section 2.4.6.1.
surfaces, comment suggested acknowledging that non-residue void type seals are available from some manufacturers and are typically used for applications where the user does not want to spend time removing remnants of past seals.
Brooks-10 2.4.1 While this section Staff have included addresses steel this description and padlocks, comment renamed section 2.4.1 suggested including a Padlock Seals to reference to a include padlocks conventional brass made of other padlock with a small materials.
hole drilled through its body and shackle for TID insertion.
Brooks-11 2.4.1 Comment suggested The NRC is in the including seals that process of acquiring meet the requirements ISO standards for staff of ISO-17712. review. If staff find that ISO-17712 meets NRC requirements this will be reflected in future revisions of this regulatory guide.
Brooks-12 2.4.2 Comment suggested NRC still finds E-Cup that E-Cup Seals are Seals acceptable for no longer a preferred use.
choice of seal.
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Brooks-13 2.4.4 Comment suggested a NRC cannot endorse more detailed specific commercial description of the fiber products. Some optic seal system. additional detail has been added to this section but references to the precise number of fiber optic strands and other details that may indicate a specific brand or model of fiber optic seal are not included.
Brooks-14 2.4.5 Comment suggested This section refers to that the tamper- tamper-evident wire evident wire seals seals in general.
metal trap be identified Section 2.4.2 as an E-Cup. discusses E-Cup type seals.
Brooks-15 2.4.5 Comment suggested A more generic referencing new types description of these of TIDs with specific other TIDs has been features and bar- incorporated into codes laser etched in 2.4.5.
the TID.
Brooks-16 2.4.6.1 Comment provided a This information has extensive detailed been included except description of void for reference to covert seal types. seals. NRC staff have not reviewed covert seal technology sufficiently to include in this regulatory guide at this time.
Brooks-17 2.4.6.2 Comment pointed out Section has been that holograms can be reworded to state that imprinted directly on a some manufacturers void-type seal. may be able to incorporate a hologram directly onto the seal.
Brooks-18 2.4.6.3 Comment suggested Section 2.3.6.3 has additional reference to been reworded to security tapes which clarify that these types transfer a layer of of security tapes are adhesive onto the included and that the surface if removed, difficulty of removing a which is difficult to residual adhesive remove even with a layer is dependent razor blade. upon both the nature of the surface to which 12/10/2010 Page 6
the label is applied and the nature of the adhesive in the seal.
Brooks-19 2.4.6.5 Comment pointed out This comment has that optical chemical been included.
coatings contribute to a seals authenticity.
Brooks-20 2.4.6.5 Comment suggested Section has been including another type amended to include of chemical coating, a chemical taggents.
chemical taggent.
Brooks-21 2.5 Comment suggested Except for the that several other reference to RFID field-verifiable TIDs readers (See Staff warrant serious Response to Brooks-consideration. 1), this information has Validation of tamper been incorporated.
evident labels and tape require no special tools. Simple observation of a void message within the label, or on the applications surface, should afford clear tamper evidence.
Individual strands of thinner diameter cable seals should individually come part to reveal tampering.
Use of a simple, inexpensive, hand-held bar code/
passive, RFID reader will quickly identify any irregularity when read results are compared with information collected previously.
Brooks-22 3.2 Comment noted that This section has been consideration should amended to suggest be given to ease of licensees consider the handling and applying environment in which seals when wearing personnel are applying gloves. TIDs, including whether or not personnel protective equipment is required.
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